Privacy Policy

_{Date of update: December 28, 2024}

Visagio Consultoria Assessoria e Desarrollo Ltda., its subsidiaries and affiliates (“Visagio”) understand that your privacy is important to You. Thus, we are committed to respecting your privacy and protecting your Personal Data, providing You with greater control.

This Privacy Policy describes how we collect, use, and protect [1] your personal information, as well as your rights related to your Personal Data. Our commitment is to ensure transparency and security in the treatment of your information, complying with applicable laws and promoting a reliable experience on our services.

We recommend that you read this Policy carefully to understand how we take care of your data and how you can exercise your rights.

1. Definitions

Notwithstanding other definitions contained in this Policy, the following capitalized terms shall have the meanings set out below:

”Personal Data” means any information related to an identified or identifiable natural person. For the purposes of this Policy, the term Personal Data (including its variation in the plural form) includes any Sensitive Personal Data, which refers to certain Personal Data with discriminatory potential, such as data related to racial or ethnic origin, sexual orientation, family income, and special needs.

”In charge” or”DPO” means the person appointed by the controller and operator to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (”ANPD”)

”LGPD” means Law No. 13,709/2018, the Brazilian General Personal Data Protection Law.

”Treatment” means any operation carried out with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

”Visagio” means Visagio Consultoria Assessoria e Desarrollo Ltda, as well as its subsidiaries and affiliates. Any reference to the terms”Our” and”we” should be interpreted as referring to Visagio.

”you” or”Individual” means the owner of the Personal Data. Any reference to the terms”Seu” and”Your” should be interpreted as referring to You.

2. Personal Data Collected

Visagio collects Personal Data to enable the provision of its services and the development of its activities. When using our services or interacting with Visagio, you entrust us with your information, and we are committed to treating it with security and transparency. The following are the main personal data processing activities according to the main purposes, affected owners, legal hypotheses and categories of personal data processed

1. ‍Use of Cookies. To enhance your experience on the Visagio website and provide personalized services, we use cookies. These small files allow us to collect information about your browsing and preferences.
   When you access the Visagio website and/or app, even without carrying out any activity, we automatically receive certain information about you. To better understand what cookies are, how they work, what data we collect through them and the reasons for this collection, access our Cookies Policy at this link.
2. ‍Recruitment and Selection. When you apply for one of our available vacancies, Visagio may use your Personal Data to feed the recruitment and selection platform that we use. In this context, the following Personal Data, provided by You, may be collected in order to enable your application and participation in our selection processes:
   (a) Identification data: civil name, social name, social security number, date of birth, nationality, and full address;
   (b) Contact details: e-mail, cell phone, and telephone;
   (c) Demographic data: race/ethnicity, gender, gender identity, pronoun [2] used, and sexual orientation;
   (d) Academic Information: educational history, income ratio (CR), training, courses and certificates;
   (e) Professional experience: previous jobs and positions held;
   (f) Social networks: profiles linked to social networks, when applicable.
   
   Additionally, depending on the nature of your application, Visagio may request information related to your professional preferences, experiences, and other details that make up your resume.
   
   Collection of Sensitive Data as part of recruitment and selection processes. As already mentioned above, but seeking even greater transparency, note that for recruitment purposes, and with your consent or when permitted by law, Visagio may collect sensitive Personal Data, such as: medical information, union engagement, race/ethnicity and gender data, and biometric data.
   
   This data is treated for specific purposes, such as the granting of benefits associated with diversity, compliance with legitimate legal obligations, and compliance with internal anti-discrimination policies.
   
   Use of Social Network Accounts. If you choose to link your social media accounts to Visagio for login, you are authorizing us to access the information contained in your public profile. This information may include: email address, photo, gender, location, and language, depending on the privacy settings of the social network used. If you want to disconnect your Visagio account from your social network, simply adjust the settings directly on the social network platform or [3]
3. Participation in Events and Registrations. When you register to participate in events organized by Visagio, whether online, face-to-face or university, or when you register to receive marketing emails, access our training portals or use the VAI Academy, we collect the following Personal Data provided by You: name, cell phone number, e-mail, company where you work, university, course and academic period.
4. ‍Participation in the Top of Mind Research. When you sign up to participate in the survey Top of Mind promoted by Visagio, we collect the following Personal Data provided by You, with your consent, except when strictly necessary for the execution of a contract to which You are a party: university and course in which you study, area of interest for professional practice, academic period, expected graduation, state in which you are studying or graduating, sex, gender, color/race, sexual orientation, participation in academic groups and other information that allows us to understand your preferences in relation to the work environment and events college students.
5. ‍Participation in Visagio Internal Events. When registering for internal Visagio events that require the issuance of airline tickets, we collect and process the following Personal Data provided by You: full name, ID, institutional email, city and airport of departure, and shirt size. Additionally, to ensure the protection of your life and physical integrity, we process information related to your dietary restrictions, also provided by You.
6. ‍Representation or Negotiation on behalf of Suppliers or Customers. When you represent or negotiate with Visagio on behalf of one of our suppliers or clients, or when executing a contract signed with Visagio, we collect the Personal Data necessary to enable the negotiation and signing of contracts, such as: name, ID and social security number, date of birth, email and address.
7. ‍Participation in Judicial, Administrative, or Arbitral Proceedings. If you are a party to a judicial, administrative or arbitral proceeding to which Visagio is also a party, we may process the following Personal Data to enable the regular exercise of rights within the scope of the process: name, ID and social security number, e-mail, mother's name, salary, address, professional registration number, as well as any other Personal Data necessary in the context of the process so that we can protect our interests.
8. ‍Making Payments or Issuing Financial Documents. When Visagio needs to make any payment to You as a result of a contract, a document providing for financial consideration, reimbursement, the issuance of an income report, preparation of Decore, or to organize airline tickets and accommodations on your behalf, we process the following Personal Data provided by You: name, social security number, age, e-mail, passport photo, address, salary and bank account details.
9. ‍Marketing. When You agree to receive text messages from Visagio, newsletters, articles, and marketing communications by email, including through third-party services, we process the following Personal Data provided by you: telephone number and email address. If you prefer not to receive these messages, you can adjust your preferences through the settings available on our sites and apps or directly by email and/or phone.
10. ‍Miscellaneous Purposes. To the extent permitted by the LGPD, we use Personal Data provided by You for certain other activities not listed above, such as to evaluate, improve, and personalize our services; send information, notifications about job openings that may interest you; fulfill your requests; analyze the performance and operation of our sites and applications; prevent fraud, spam, and abuse; and enforce our Policies and all applicable regulatory obligations.

2.1. Links to Third Party Sites

Our materials may, from time to time, contain links that redirect You to third-party sites. The Personal Data provided by You on these sites will not be subject to this Privacy Policy, and the way in which those sites treat Your Personal Data is not our responsibility.

By accessing links to other sites, you acknowledge and agree that such sites have their own privacy policies, which will define how your information will be collected, treated, and protected during your browsing. We recommend that you carefully consult the respective privacy policies to understand how your Personal Data will be used by those sites or tools.

Visagio is not responsible for the content or privacy practices of third parties. In addition, we do not share, subscribe to, monitor, evaluate, or accept the practices adopted by these sites or content storage tools for the collection, treatment, and transfer of your Personal Data.

2.2. Use of Public Forums and Content Sharing

By sharing content or communicating with individuals and companies through our public forums, the information provided by You becomes public and can be accessed by anyone, regardless of whether they are registered with our services.

In addition to the shared content, additional information about your post, such as date, time, location, and interactions, will also be made public. Your activities, such as comments, likes, or other forms of interaction, will be equally accessible to the public.

You are solely responsible for the information you choose to make public. We recommend caution when sharing content, especially if it involves Sensitive Personal Data. When such data is made public, Visagio may provide access to that information or share it with people inside and outside of our services, including through apps. Additionally, this information may be widely disclosed by third parties not affiliated with Visagio, such as online search engines.

If you do not want Visagio to access or process Personal Data and Sensitive Personal Data, we ask that you do not provide such information on our sites or apps.

3. Legal Hypotheses for the Use of Personal Data

The Personal Data collected will be used to guarantee the maintenance of our services and the development of our activities when there is a legitimate interest, with your specific consent, for the execution of contracts to which You are a party, for the compliance with legal or regulatory obligations, for the regular exercise of our rights or for the protection of the life and physical safety of You or third parties.

The legal hypothesis applied to each purpose of processing Personal Data provided for in item 1 of this Policy strictly complies with the LGPD.

3.1. Use of Information Collected Via Mobile Devices

In relation to our mobile applications, Visagio may use third-party service providers to analyze user activities in an anonymized form, with the purpose of correcting errors, monitoring the use, and improving the performance of those applications. For example, Visagio receives reports containing aggregated usage and navigation patterns, such as information about the type of device used, the content accessed and other events recorded in the applications, ensuring that the data analyzed does not personally identify the users [4].

4. Transfer and Sharing of Personal Data

4.1. International Transfer[5]

Considering the international operations of Visagio and its affiliates, and to meet the needs of each Personal Data Processing operation, and only in the cases permitted by Brazilian law, we may transfer, store and process your Personal Data in any country where we carry out our activities.

In cases of international data transfer, we will adopt appropriate measures to ensure that the treatment complies with the LGPD and with the International Data Transfer Regulation, approved by Resolution CD/ANPD No. 19, of August 23, 2024.

When we transfer Personal Data to other countries, we recognize that local laws and regulations may vary. However, we seek to ensure an adequate level of protection for your rights, evaluating compliance with the data protection rules of the receiving country and/or the established contractual obligations.

If you need more information about these legal mechanisms, including the standard contractual clauses disclosed by the ANPD, please contact us at the address indicated in item 11.

4.2 Transfer of Ownership

If Visagio becomes a party or participant in a bankruptcy, merger, acquisition, corporate reorganization, or any other procedure involving the transfer or restructuring of total or partial ownership of our assets and services, your Personal Data may be transferred, as part of that transaction, to the new controlling entity or to third parties involved in the process.

This type of transfer may occur in the context of a sale, transfer, or sharing of business assets, and your Personal Data may be processed by the new controller in accordance with applicable law. In this case, we will take reasonable steps to ensure that the privacy and security of your Personal Data is maintained and that the processing of that data is carried out in accordance with this Privacy Policy, the LGPD and the relevant legal obligations.

If the transfer involves significant changes in the processing of your Personal Data, we will notify You in advance and, where applicable, we will request your consent, as required by law.

4.3. Sharing

In order to ensure the continuity and efficiency of our activities, and within the strictly necessary limits, Visagio may share and/or transfer your Personal Data to our affiliates, subsidiaries, professional advisors, public and governmental authorities, as well as to our third-party service providers, located anywhere in the world.

When the transfer is required by law or regulation, we adopt appropriate legal mechanisms to ensure that your Personal Data is treated securely and with the necessary protection. These mechanisms include contractual clauses, contracts with service providers and, when applicable, other measures provided for by Brazilian and international law, with special attention to the LGPD.

Visagio may also share, provide access to, and/or transfer your Personal Data to third parties contracted to provide services related to our sites, apps, contracts, and other functions they perform on our behalf. These third parties will provide services that aim to support our interaction with you, such as hosting services, data analysis, payment services, and others, and will be committed to maintaining confidentiality and providing a level of data security equivalent to that required by us.

We always seek to ensure that any processing of Personal Data carried out by our service providers is consistent with this Privacy Policy, and that the practices adopted by these third parties respect the confidentiality, integrity, and availability of your Personal Data, ensuring that everyone involved treats this information with the same level of security provided by Visagio.

5. security

Visagio adopts strict technology and operational security standards, including technical and organizational measures, to protect your Personal Data against accidental loss, misuse or unlawful treatment, alteration, disclosure, unauthorized access, damage, or destruction. The purpose is to guarantee the accuracy of the data, prevent unauthorized access and ensure the appropriate use of the information. In addition, we use tools to detect and respond to fraud, abuse, and security risks that may compromise the reliability of our platforms.

The solutions adopted to protect Personal Data are chosen based on factors such as the nature, context, purpose of the processing, the costs involved, and the risks to your rights and freedoms. Only authorized Visagio personnel and trusted third-party service providers have access to this data, all of whom are required to treat it with due diligence and as confidential information, in accordance with current legislation.

While we take security measures appropriate to industry standards, the risk of transmitting information electronically cannot be fully eliminated. Thus, we cannot guarantee that the Personal Data provided will not be intercepted during Internet transmission.

Visagio is not responsible for failures attributable to third parties, such as attacks by hackers or crackers, or due to the individual's own negligence, such as when they transfer their data to third parties. In the event of a security breach that could compromise your rights and freedoms, Visagio undertakes to notify you in an appropriate manner and within a reasonable time.

6. Retention of Collected Personal Data

Your Personal Data will be kept by Visagio for the period necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy. Thus, the data will be stored until the need for its treatment ceases.

Whenever possible, your personal information will be automatically deleted. However, the processing and deletion of data may vary depending on the nature of the information, the purpose of the processing and any legal obligations or operational needs.

Visagio may retain your Personal Data for a period longer than the period of the business relationship, in order to guarantee the security of processing, compliance with court orders, legal and regulatory obligations, or for the exercise of the right to defend or prosecute legal actions. We may also retain data to comply with our internal policies and information management practices, including transfers to third parties, provided that applicable legal requirements are observed, or for the exclusive use of Visagio, provided that it is anonymized and without access by third parties.

After the retention period, as applicable, your Personal Data will be permanently deleted and rendered useless by Visagio, in order to guarantee its total destruction and security.

7. Personal Data of Children and Adolescents[6]

We do not direct our services to children and adolescents under 13 years of age. Therefore, Visagio does not intentionally collect or maintain Personal Data about someone under that age.

For the promotion and execution of events aimed at university audiences, Visagio may process Personal Data of adolescents, and it is certain that it will do so in the best interest of the minor, in accordance with article 14 of the LGPD.

8. Your Rights

Visagio, in compliance with the LGPD, guarantees and provides tools so that You can exercise, upon request, your rights related to the Personal Data that is being processed. These rights include:

1. Updating, correcting, anonymizing, or removing your Personal Data;‍
2. Access to data under treatment;
3. Restriction or opposition to the processing of your data;
4. Information about sharing your information with other service providers and/or product suppliers;
5. Receipt of confirmation about the processing of your information.

In addition, you have the right to request, at any time, a file containing a copy of the Personal Data that Visagio collects and maintains about you.

In the case of processing based on your consent, such as in the case of sensitive Personal Data, you can revoke the consent at any time.

Some of these rights can be exercised directly by You, as in the case of unsubscribing from mailing lists or on our websites and apps. To do this, simply access the page where you provided the information or registered, or contact us using the channel provided below.

The following rights are also at your disposal and can be exercised at any time:

1. Right to confirm and access your Personal Data;
2. Right to rectify incorrect or outdated data;
3. Right to delete data, except in situations involving legal or regulatory obligations;
4. Limitation of the processing of your Personal Data;
5. Right to object to data processing, when applicable;
6. Right to data portability;
7. Right not to be subject to automated decisions.

While we fully respect your rights, Visagio may refuse requests that are manifestly unfounded, excessive, or unfeasible, depending on the purposes of the processing of Personal Data. If we are unable to fulfill a request, we will inform you of the impossibility and provide a reasoned explanation.

Once we receive your request, we strive to respond to it as quickly as possible. We emphasize that, in the event of a request for data deletion, the minimum storage period, in accordance with Brazilian standards, will be respected.

To exercise any of your rights or to clarify questions, please contact us through the channel indicated in the”Contact us“and also pay attention to the provisions in the section”Retention of Collected Personal Data“above.

9. Application of this Privacy Policy

This Privacy Policy does not apply to Personal Data Processing carried out by companies other than Visagio, even if indicated by us in our websites and apps. Such collection and/or treatment services will compete solely and solely with the companies that offer them and will therefore be exclusively subject to their respective privacy policies.

10. Changes to the Privacy Policy

We reserve the right to change this Privacy Policy from time to time and we always highlight the date of publication of the last change. If we make relevant changes, capable of expanding our rights to the Processing of your data, or otherwise substantially modifying this Policy, we will send a notice to that effect to the email address you provided to us, and/or we will publish information about the changes in our websites.

11. Contact us

If you want to clarify questions about our Privacy Policy or need assistance, please contact us at the email address: privacy@visagio.com or, if you prefer in person, at the nearest Visagio office, the addresses are available on our websites.

Now, if you want to contact

1. Make a complaint;
2. Confirm the existence of Processing of your Personal Data;
3. Correct incomplete, inaccurate, or outdated Personal Data;
4. Request the deletion of Personal Data processed with your consent, except for the hypotheses provided for in current legislation;
5. Obtain information about the possibility of not providing consent and about the consequences of such refusal;
6. Revoke consent for the Processing of your Personal Data, except for the hypotheses provided for in current legislation;
7. Exercise any of the other rights of the holder of the Personal Data, in accordance with current legislation,

You can contact our Personal Data Processor [7], Thales Pires, at the email address: dpo@visagio.com.